2900-0055 justification

SUPPORTING STATEMENT FOR VA FORM 26-1817,

REQUEST FOR DETERMINATION OF LOAN GUARANTY ELIGIBILITY

UNMARRIED SURVIVING SPOUSES

(2900-0055)

A. JUSTIFICATION

1. Title 38, U.S.C. 3701(b)(2), authorizes VA to extend home loan benefits to unmarried surviving spouses of veterans whose deaths (1) occurred either while serving on active duty or (2) were a direct result of service-connected disabilities.

2. Section 3702(c) of Title 38, U.S.C. states that any veteran may apply to the Secretary for a certificate of eligibility. A completed VA Form 26-1817 constitutes a formal request by an unmarried surviving spouse for a certificate of eligibility. Upon receipt of VA Form 26-1817 and the required documentation by Loan Guaranty personnel, the application and supporting documents are referred to the Adjudication activity via the Administrative activity for determination of the applicant's basic eligibility. Adjudication will then notify Loan Guaranty about the basic eligibility for issuance of the certificate of eligibility. The information collected on the form provides the essential information necessary for VA to make a proper determination.

3. VA Form 26-1817 requires very specific information that is collected from individuals. Use of improved information technology in gathering this information would be of limited benefit. The form requires the applicant to provide identifying information about the deceased veteran which may not always be contained at the time in VA data systems. Additionally, once the form is submitted to Loan Guaranty, it is usually referred to the Veteran’s Service Center. In many cases that division must request military service records and manually review them in order to determine if the applicant meets the definition of an unmarried surviving spouse.

4. The information is not contained in any other VA records. The information contained in the form relates to an individual's eligibility status.

5. The collection of information does not involve small businesses.

6. The information collected is completed by applicants frequently with the assistance of a casualty assistance officer when an original claim for benefits is requested by an unmarried surviving spouse. This completed form is used to establish eligibility for loan guaranty benefits. The collection is generally conducted once per individual applicant.

7. There are no special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.6.

8. The agency notice was published in the Federal Register on November 24, 2010, pages 71796-71797. There were no comments received in response to this notice.

9. No payments or gifts to respondents have been made under this collection of information.

10. Loan Guaranty Home, Condominium and Manufactured Home Loan Applicant Records, Specially Adapted Housing Applicant Records, and Vendee Loan Applicant Records - VA (55VA26) contained in the Privacy Act Issuances, 2001 Compilation.

11. No sensitive questions appear on the form.

12. Estimate of Information Collection Burden

a. Number of respondents is estimated at 3,649 per year.

b. Frequency of response is generally one time.

c. Annual burden is 912 hours.

d. The estimated response time of 15 minutes is based on informal consultations with staff personnel who have had actual experience in completing the form with the applicant.

e. The total estimated cost to respondents is $13,680 (912 hours x $15 per hour).

13. This submission does not involve any recordkeeping costs.

14. Estimate of Cost to Federal Government

$15,228 Estimated Loan Guaranty processing cost for FY 2010

(3,649 cases x 10 minutes per case x $25.04 per hour (average Loan

Guaranty field salary))

$28,831 Estimated Veteran’s Service Center processing cost for FY 2010

(1800 cases x 15 minutes processing time by GS-4 ($14.59 per hour) plus 30 minutes processing time by GS-9 ($24.74 per hour)
___

$44,059 Total estimated cost to the Government

15. There is an increase in burden hours. This is due to a rise in the number of service-connected deaths in relation to the ongoing conflicts in the Middle East.

16. Information collection is not for tabulation or publication use.

17. The collection instrument, VA Form 26-1817, may be reproduced and/or stocked by the respondents and veterans service organizations. This VA form does not display an expiration date, and if required to do so it would result in unnecessary waste of existing stocks of this form. These forms are submitted to OMB for approval every 3 years. As such, this date requirement would also result in an unnecessary burden on the respondents and would delay Department action on the benefit being sought. VA also seeks to minimize its cost to itself of collecting, processing, and using the information by not displaying the expiration date. For the reasons stated, VA continues to seek an exemption that waives the displaying of the expiration date on VA Form 26-1817.

18. There is no exception to the certification statement identified in Item l9,

"Certification for Paperwork Reduction Act Submissions," of OMB Form 83-1.

B. STATISTICAL METHODS

The Veterans Benefits Administration does not collect information employing statistical methods.